"I do think the rule in Gibbs has its benefits," said Allen and Overy partner Jennifer Marshall,
a lawyer with expertise in restructuring and insolvency. "It
offers certainty to those who are drafting contracts because,
without that rule, if you had an English law document it could
be discharged or varied by compromise proceedings in another
jurisdiction."

While it has cushioned lenders active in the emerging
markets, it has drawn criticism due to the fact it can be
perceived as isolationist, acting against the interest of
cross-border cooperation.

KEY TAKEAWAYS

The rule in Gibbs has helped uphold the rights of
holders of Eurobonds issued by the International Bank of
Azerbaijan;Experts feel Gibbs...